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Category:AFFIDAVITS
MONTHYEARML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20057B0261993-08-0909 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance Activities at Plant ML20057B0301993-08-0505 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance of Activities at Plant ML20057B0271993-08-0505 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Re Maint & Surveillance Activities at Plant ML20057B0181993-08-0404 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from Rept Prepared by INPO Re Maint & Surveillance Activities at Plant ML20057B0221993-08-0404 August 1993 Affidavit of non-disclosure in Support of Access to Excerpts from INPO Rept Re Maint & Surveillance Activities at Plant ML20045G9811993-06-30030 June 1993 Affidavit.* INPO Rept Should Not Be Disclosed Because San Luis Obispo Mothers for Peace Need for Document Do Not Outweigh Interests of Pg&E,Inpo & NRC & Public in Disclosure.W/Certificate of Svc ML20045G9821993-06-25025 June 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Response to Third Set of Supplemental Interrogatories & Requests for Production of Documents (Aging) Filed by San Luis Obispo Mothers for Peace ML20045G9901993-06-25025 June 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Supplemental Response to Second Set of Interrogatories & Requests for Production of Documents Filed by San Luis Obispo Mothers for Peace ML20045A7031993-05-26026 May 1993 Affidavit of Je Molden Re Util Response to Supplemental Interrogatories Re First Set of Interrogatories & Requests for Production of Documents (Cable Failures) ML20045A7041993-05-26026 May 1993 Affidavit of Je Molden Re Util Response to Miscellaneous Requests for Production of Documents ML20045G9931993-04-13013 April 1993 Affidavit.* Affidavit of Bw Giffin Re Info Contained in Util Response to Second Set of Interragotories & Request for Production of Documents Filed by San Luis Obispo Mothers for Peace ML20128B8341992-11-30030 November 1992 Affidavit of as Masciantonio in Support of NRC Staff Response to Mothers for Peace Suppl to Petition to Intervene.* W/Certificate of Svc ML20116F0631992-10-0707 October 1992 Affidavit of R Becker.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed ML20116F0361992-10-0606 October 1992 Affidavit of N Culver.* Affidavit Re Safety Concerns of Plant Operation During CP Recapture ML20116F0701992-10-0606 October 1992 Affidavit of Biesek.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed. Encl ML20116F0551992-10-0606 October 1992 Affidavit of E Holder.* Concerns Re Safety of Plant Operation During Period of CP Recapture Expressed ML20235S0091987-10-0202 October 1987 Affidavit of Jd Shiffer.* Explains Util Planned Expansion of Facility Spent Fuel Storage Capacity & Why Delay in Reracking Schedule,Such as Would Be Occassioned by Stay,Will Cause Substantial Harm to Util.Certificate of Svc List Encl ML20216J8641987-06-29029 June 1987 Declaration of Ef Lowry.* Tm Novak Board Notification 87-05 Re Draft BNL Rept Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82) Received in Late Mar or Early Apr 1987.Proof of Svc Encl ML20216J8471987-06-26026 June 1987 Affidavit of SA Silver Informing That Draft BNL Rept, Beyond Design-Basis Accidents in Spent Fuel Pools (Generic Issue 82) Not Received ML20216J8191987-06-25025 June 1987 Affidavit of RB Ferguson Re Notification of Generic Issue 82.* Board Notification 87-05 Re Generic Issue 82 Concerning Beyond design-basis Accidents in Spent Fuel Pools False & Misleading ML20216J8371987-06-25025 June 1987 Affidavit of N Culver Informing That Board Notification 87-05 Re Draft BNL Rept on Spent Fuel Pool Accidents Never Received ML20213A0331987-01-13013 January 1987 Affidavit of Kp Singh Re Mothers for Peace & Sierra Club 861215 Motion for Summary Disposition Concerning Design of high-density Spent Fuel Racks.Racks Designed in Compliance W/Applicable NRC & SRP Requirements.Certificate of Svc Encl ML20205F6271986-08-15015 August 1986 Affidavit of Pw Niles Reporting Results of Calculations Performed on Postulated Hosgri Event Data ML20206J4201986-06-24024 June 1986 Affidavit of Rc Herrick on 860624 Re Intervenors 860616 Application for Stay & RB Ferguson Affidavit Re Proposed Reracking of Spent Fuel Storage Sys ML20206J4751986-06-24024 June 1986 Affidavit of Wl Brooks Re Intervenors 860616 Application for Stay & RB Ferguson 860616 Affidavit Re Expansion of Spent Fuel Pools.Certificate of Svc Encl ML20206D7501986-06-18018 June 1986 Affidavit of Jd Shiffer Re Proposal to Increase Spent Fuel Storage Capacity,Approved by NRC on 860530.Intervenor Risk Allegations Refuted.W/Certificate of Svc ML20199D1271986-06-15015 June 1986 Affidavit of RB Ferguson Concluding That Spent Fuel Reracking at Facilities Presents Significant Safety Hazard to Surrounding Environ & Population & Poses Risk of Irreversible Contamination ML20099H6491985-03-0505 March 1985 Affidavit of a Jackson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Technical & Safety Significance of Issues Raised in 841115 Affidavit Re Flud Computer Program.Errors in Program May Lead to 100% Inaccurate Predictions ML20099H6261985-03-0404 March 1985 Affidavit of L Kinney Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Charges of Matl False Statements by Util in Response to Allegations Jir 75-78 & 80 ML20099H6061985-02-24024 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Concern Over NRC Response to 841127 Disclosure of Significant Engineering Errors & QA Violations in Design of Pipe Supports ML20099H7281985-02-22022 February 1985 Affidavit of Tj O'Neill Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Matl Licensing Issues Resolved by NRC on Basis of False Statements & Omissions.Failure of Diablo Canyon Allegation Mgt Program Described.New Info Encl ML20099H5021985-02-0606 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Deficiencies W/Engineering Practices on Large Bore Piping & Pipe Supports ML20099H5591985-02-0404 February 1985 Anonymous Affidavit Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re QA Problems in Drafting Dept,Hardware Deficiencies,Mgt Opposition to Reporting Deficiencies to QA & Failure to Follow Engineering Specs ML20099H5741985-01-23023 January 1985 Affidavit of Ho Hudson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Deficiencies in Cardinal Industrial Products Qa.Corrective Actions Did Not Address Matls Previously Installed.Supporting Documents Encl ML20099H7751985-01-23023 January 1985 Affidavit of Mc Thompson Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Addl Concerns on Issues Examined in 850108 Interview.Supporting Documentation Encl ML20099H5271985-01-22022 January 1985 Affidavit of P Haffey Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Allegations of Misconducting by Region V & of Util Matl False Statements Concerning Previous Allegations ML20099H6631985-01-21021 January 1985 Affidavit of Jl Mcdermott Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re NRC Mishandling of Previous Allegations.Fifteen New Allegations Listed ML20099H7541985-01-18018 January 1985 Affidavit of CC Stokes Supporting Jl Mcdermott & Tj O'Neill 840731 Petition Re Failure of NRC to Honor Rules of Allegation Mgt Program & Matl False Statements by Util in Response to Previous Allegations ML20107C4871984-11-0101 November 1984 Affidavit of Tm Devine Re Employee Concerns That Reactor Vessel Level Instrumentation Sys May Not Provide Reliable Readings ML20107C5011984-10-29029 October 1984 Affidavit of Lockert Re Const Qa,Licensee Character & Competence ML20107C4751984-10-22022 October 1984 Marked-up Affidavit of Mc Thompson Re Possible Fake Welds on Stanchions Holding Up Safety Injection Sys Lines in Unit 1 ML20098F9381984-10-0101 October 1984 Affidavit of Mj Jacobson & Tg De Uriarte,Signed Only by Tg De Uriarte,Re QA Program.Certificate of Svc Encl ML20093N2341984-07-30030 July 1984 Affidavit of Jl Mcdermott Re Need for Reinsps & Systematic Retraining of All Personnel at Facility ML20093K0621984-07-27027 July 1984 Affidavit of Dh Hamilton Re Location & Subsurface Geometry of Hosgri Fault & Tectonic Deformation in Region of Fault ML20093K0811984-07-27027 July 1984 Affidavit of Wh White Re Hosgri Fault Design Bases. Certificate of Svc Encl ML20093K0691984-07-26026 July 1984 Affidavit of SW Smith Re Regional Seismicity & Morgan Hill Earthquake ML20093J3481984-07-24024 July 1984 Affidavit of DG Bridenbaugh,Restating 810811 Affidavit Re Potential Hazards of built-up Fission Products Release. Certificate of Svc Encl ML20090A8501984-07-11011 July 1984 Affidavit of T Devine Notifying of Resignation of I Yin from Review Team Overseeing Plant Readiness for Commercial Operation ML20092B6621984-06-19019 June 1984 Affidavit of DA Rockwell Re Allegations of Mgt Harassment. Related Correspondence 1994-03-04
[Table view] Category:LEGAL TRANSCRIPTS & ORDERS & PLEADINGS
MONTHYEARDCL-99-123, Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations1999-09-20020 September 1999 Comment on Prs 10CFR50 & 72 Re Reporting Requirements for Nuclear Power Reactors & Draft NUREG-1022, Event Reporting Guidelines. Util Areas of Concern Includes ESF Actuations, Significantly Degraded Components & Historical Limitations ML20205N4081999-04-14014 April 1999 Comments Opposing Proposed Rules 10CFR2,19 & 20 Re Proposed Repository at Yucca Mountain.Requests Information on How Much Radiation Being Released Now at Diablo & Hanford NPPs ML20205N4601999-03-21021 March 1999 Introduces K Schumann as Representative of Nuclear Waste Committee (Nuwic) of San Lius Obispo County.Informs That Nuwic & Nuclear Waste Management Committee Concerned with Transportation of Spent Nuclear Fuel Rods from Dcnpp ML20195E8841998-11-24024 November 1998 Petition for Mod to OLs to Require Plant Owner to Have Independent Contractor Evaluate Plant Safety Culture ML20236T3011998-07-24024 July 1998 Order Prohibiting Involvement in NRC Licensed Avtivities (Effective Immediately).Lh Brooks Prohibited for 5 Yrs from Date of Order from Engaging in NRC Licensed Activities ML20248C2261998-05-22022 May 1998 Comment Opposing Revised Proposed Rule 10CFR50 Re Protection & Safety Sys ML20129J4191996-10-18018 October 1996 Order Approving Application Re Corporate Restructuring of Pacific Gas & Electric Company by Establishment of Holding Company DCL-95-206, Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations1995-10-0606 October 1995 Comment Supporting Petition for Rulemaking PRM-50-61 Re Improving Fire Protection Regulations ML20091P8721995-08-23023 August 1995 Comment Opposing Petition for Rulemaking PRM-50-61 Re Nuclear Energy Institute Proposed Amends on Fire Safety for All NPPs DCL-95-001, Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments1995-01-0303 January 1995 Comment on Proposed Changes to Reactor Pressure Vessel Integrity Rule 10CFR50.Endorses NEI Comments ML20077M7521994-12-30030 December 1994 Comment Opposing Proposed Rule 10CFR50 Re Shutdown & Low Power Operation for Nuclear Power Reactors DCL-94-270, Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal1994-12-0808 December 1994 Comment on Proposed Rules 10CFR2,51 & 54 Re Rulemaking for NPP License Renewal.Endorses Comments & Changes Proposed by NEI 941208 Submittal ML20149H0851994-11-0404 November 1994 Initial Decision (Construction Period Recovery/Recapture).* Renewed Motion to Reopen Record 940808,denied.Served on 941104.W/Certificate of Svc ML20072L2651994-08-23023 August 1994 PG&E Opposition to San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record.* Util Opposes San Luis Obispo for Peace Motion Based on Affidavit Stating No Evidence Found in Motion Re Flaw in Program.W/Certificate of Svc ML20072F0291994-08-12012 August 1994 Erratum to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Intervenors Corrects Error in Renewed Motion to Reopen Record Re Application for License Amend to Extend Term of Operating License for Plant.W/Certificate of Svc ML20072B2651994-08-0909 August 1994 Comment Supporting Proposed Rule 10CFR26 Re FFD Requirements Concerning Random Drug Testing ML20072A5821994-08-0808 August 1994 San Luis Obispo Mothers for Peace Renewed Motion to Reopen Record Re PG&E Application for Amend to Extend Term of OL for Plant.* Motion to Reopen Record to Introduce Insp Rept Identifying Alleged Problems W/Plant.W/Certificate of Svc ML20071L2061994-07-26026 July 1994 Comment Supporting Proposed Rule 10CFR26 Re Changing Current Drug Testing Policies to Exclude All Personnel in nonsafety-related Positions ML20072B8481994-07-26026 July 1994 Comment Opposing Proposed Rule 10CFR26 Re Changes to FFD Requirements Concerning Random Drug Testing ML20071L1901994-07-20020 July 1994 Comments on Proposed Rule 10CFR26 Re Relaxing Rule on Drug Testing of Employees Working at NPP DCL-94-134, Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-60 Re Amend to 10CFR50.54 by Changing Frequency W/Which Each Licensee Conducts Independent Reviews of Emergency Preparedness Program DCL-94-135, Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs1994-06-27027 June 1994 Comment Supporting Petition for Rulemaking PRM-50-59 Re Proposed Amend to 10CFR50.54(p) Concerning Frequency W/Which Licensee Conducts Independent Reviews of Security Programs ML20064D1791994-03-0707 March 1994 Pacific Gas and Electric Co Reply in Opposition to San Luis Obispo Mothers for Peace Motion to Reopen Record.* Motion to Reopen Record Denied.W/Certificate of Svc ML20064D1961994-03-0404 March 1994 Affidavit of Mj Angus Re Motion to Reopen Record ML20063L5721994-02-25025 February 1994 San Luis Obispo Mothers for Peace Re Util Application for License Amend to Extend Term of Operating License for Plant.* Advises That Record of Proceeding Should Be Reopened to Consider Insp 93-36 Re Util Surveillance of Asw Sys DCL-94-021, Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation1994-01-26026 January 1994 Comment Supporting Petition for Rulemaking PRM-21-2 Re Commercial Grade Item Dedication Facilitation ML20059D2431994-01-0707 January 1994 Package of Intervenor Exhibits Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20062N0001993-12-30030 December 1993 PG&E Reply Findings of Fact & Conclusions of Law.* Mothers for Peace Proposed Findings & Conclusions Do Not Provide Any Supportable Rationale to Change Findings & Conclusions Previously Proposed by Pg&E.W/Certificate of Svc ML20058P3931993-12-22022 December 1993 NRC Staff Findings of Fact & Conclusions of Law in Form of Initial Decision.* Certificate of Svc ML20058K7491993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Board Has Extended Filing Time for Util Until 931230.W/Certificate of Svc. Served on 931206.Granted for Board on 931203 ML20058K8771993-12-0202 December 1993 NRC Staff Motion for Extension of Time.* Requests That Board Extend Date for Staff to File Findings Until 931222. W/Certificate of Svc ML20059M5291993-11-19019 November 1993 Applicant Exhibits A-21,A-22,A-24,A-25,A-26,A-29 & A-F1, Consisting of Related Correspondence Not Admitted Into Evidence.Related Correspondence ML20058E0741993-11-19019 November 1993 San Luis Obispo Mothers for Peace Proposed Findings of Fact & Conclusions of Law Re Licensee Application for License Amend to Extend Term of Operating License for Plant.* W/ Certificate of Svc ML20059E8931993-10-28028 October 1993 Memorandum & Order (Motion for Extension of Time).* San Luis Obispo Mothers for Peace 931018 Request for two-wk Extension of Time to File Proposed Findings of Fact & Conclusions of Law Granted.W/Certificate of Svc.Served on 931029 ML20059E8531993-10-27027 October 1993 NRC Staff Response to Board Memorandum & Order Re Extension of Time.* Staff Believes That San Luis Obispo Mothers for Peace Has Shown No Good Cause for Requesting Extension to File Proposed Findings of Fact.W/Certificate of Svc ML20059E8631993-10-25025 October 1993 Pacific Gas & Electric Co Response to Motion for Extension of Time.* Util Does Not Agree W/Board Assessment That Mothers for Peace Request Appears to Be Reasonable But Will Not Oppose Request.W/Certificate of Svc ML20059B2191993-10-19019 October 1993 Memorandum & Order (Responses to Motion for Extension of Time).* Board Believes Intervenor Request for Extension of Time to File Proposed Findings of Fact Appears Reasonable. W/Certificate of Svc.Served on 931019 ML20059B1071993-10-18018 October 1993 San Luis Obispo Mothers for Peace Motion for Extension of Time for Filing Proposing Findings of Fact & Conclusions of Law.* Requests Extension of Two Wks or Until 931119 to File Proposed Findings of Fact.W/Certificate of Svc ML20057D0531993-09-23023 September 1993 Notice of Appearance.* Notice Given That Undersigned Attorney Enters Appearance in Listed Matter & Listed Info Provided.W/Certificate of Svc ML20057B0401993-09-14014 September 1993 NRC Staff Reply to PG&E Response to Staff Motion to Amend Protective Order.* NRC Staff Moves Board to Adopt Language Requested in 930817 Motion as Stated.W/Certificate of Svc ML20056G4891993-08-30030 August 1993 Pacific Gas & Electric Co Response to Motion to Amend Protective Order.* Staff Asks That Protective Order Be Clarified by Adding New Footnote to Paragraph 3 of Order. W/Certificate of Svc ML20059C7361993-08-24024 August 1993 Intervenor Exhibit I-MFP-88,consisting of NRC Insp of Diablo Canyon Units 1 & 2 IR 05000275/19920161993-08-24024 August 1993 Intervenor Exhibit I-MFP-137,consisting of Insp Rept Re Dockets 50-275/92-16 & 50-323/92-16,dtd 920707 IR 05000275/19930111993-08-24024 August 1993 Intervenor Exhibit I-MFP-26,consisting of Re Insp Repts 50-275/93-11 & 50-323/93-11 ML20059M1381993-08-24024 August 1993 Staff Exhibit S-1,consisting of Re 920519 Enforcement Conference IR 05000275/19920131993-08-24024 August 1993 Intervenor Exhibit I-MFP-140,consisting of 920416,mgt Meeting Repts 50-275/92-13 & 50-323/92-13 ML20059D0841993-08-24024 August 1993 Intervenor Exhibit I-MFP-139,consisting of Insp Rept Re Dockets 50-275 & 50-323,dtd 920417 IR 05000275/19920261993-08-24024 August 1993 Intervenor Exhibit I-MFP-118,consisting of Notice of Violation & Insp Rept Re Docket 50-275/92-26 & 50-323/93-26,dtd 921113 ML20059M5041993-08-24024 August 1993 Staff Exhibit S-2,consisting of Re Notice of Violation ML20059M8621993-08-24024 August 1993 Intervenor Exhibit I-MFP-35,consisting of Rept, Self- Evaluation of Diablo Canyon Power Plant, Dtd Jul 1993 1999-09-20
[Table view] |
Text
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Exhibit 1
- ~ _ _ - - .-
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION ERiGCE thg Ngg[ ggt 8ggg[g(gty Cgmg[gg{gg
)
In the Matter of )
)
PACIFIC GAS AND ELECTRIC ) Docket Nos. 50-275 COMPANY ) 50-323
)
Diablo Canyon Nuclear Power )
Plant, Units 1 and 2 )
)
AFFIDA's IT OF STATE OF CALIFORNIA SS COUNTY OF ALAMEDA
. CITY OF DERkELEY lhe above, being duly sworn, deposes and says:
My name is I am submitting this affidavit frecly and vol cntaril y , without any threats, inducements or coercion, to Mr. Thomas Devine, who has identified himself to me au the legal director of the Government Accountability Project (OAF). I am submitting this affidavit to evidence my personal lenowledge of deficiencies with engineering practices on large bore piping and pipe supports at the Diablo Canyon nuclear power plant. Dased on my review of Nuclear Regulatory Commission (NRC) inspector Isa Yin's comments in Diablo Canyon Supplemental Safety Evaluetton No. 25, I believe that I am one of the persons he would have sought to question had he been allowed to complete his irvestigation. I was in a position to be directly aware of the B503190392 850314 PDR ADOCK 05000275 O PDR , _
engineering practices'in question.
I have instructed Mr. Devine to transmit my affidavit to the NRC staff but to remove my name. Because I am actively employed within my profession as a Registered Professional Engineer, I have a lot to lose from retaliation. For that reason, this statement lists issues but does not provide supporting details or specific referances that could be traced back to me. Similarly, certain issues are not included for that same reason. I will fill in those holes during further correspondence with the NRC staff after assuring myself that my identity will be protected.
In some cases, the issues may appear duplicative of prior allegations, because I have presen'ted them in a generalized fashion to protect my anonymity. In further correspondence with a
the tiRC stafi I will provide further details necessary to assess whether en identical allegation already has been resolved, and whether my own conteibution would affect the prior, resolution. .
Further 1 have instructed Mr. Devine to withdraw this affidavit if my anonymi ty cannot be protected.
I. OVERVIEW
- 1. On balance, the report of NRC inspector Isa Yin 'on Diablo Canyon was accurate with respect to off-site consultant (s), but it failed to provide specific findings that matched the systematic scope of the quality assurance (OA) breakdown with respect to engineering work.
II. DESIGN ERRORS
- 2. The engineering calculations of off-site consultant (s) contained an unacceptable high rate of mistakes, including a high 2 .
~
rate of significant errors and some error in all but a few of the packages.
- 3. Due to the use of the wrong formula, engineering calculations for Diablo Canyon may have under estimated the stresses in welds attaching baseplates to structural steel channels and angles where torsional or twisting force was applied, to the extent that hangers which passed should have failed.
- 4. In using the STRUDL computer program used #cr Diablo Canyon there was much confusion regarding the orientation of the principel axis of beam elements. This confusion resulted in the beam elements on occasion being oriented 90 degrees from where they were orientated in fact.
~
- 5. In using the STRUDL computer program used for Diablo Canyon 6. h e use of defaults for the unbraced length of beam members on occasion resulted in an over estimation of the allowablo loads. This unconservative error could overestimate the allowable loads by up to 400%.
- 6. Due to insufficiently precine modeling in the use of the S1RUDL computer program used for Diablo Canyon, stresses on baseplates may be underestimated by 50% or more because the location at which the stresses were calculated differed from the location of manimum stress.
- 7. Decpite knowledge of inaccuracies in the STRUDL l
computer program for Diablo Canyon, management at off-site cotiuul tant (s) told employees to continue using the program as it was until instructed otherwise by Diablo Canyon Project i
Organi:ation (DCPO), which in some cases meant that the errors 3
were repeated indefinitely.
- 8. Based on International Congress of Building Officials Research Report No. 2156 and statements by Hilti personnel the use of expansion concrete anchors in areas subject to vibratory or shock loads is inappropriate. Since all power plants generate vibrations in piping during normal operation there use at Diablo Canyon is questionable.
- 9. The M-9 design guide for Diablo Canyon mistakenly allows allowable stresses approaching yield while only requiring that the members be designed to elastic criteria. If these higher allowables are to be allowed then the plastic design requirements in the AISC code should be required. Failure to meet these plastic design requirements could preclude the members from carrying the req'uired loads,
- 10. Due to an error in the M-9 design guide used to calculate allowable stresses, pipe supports throughout Diablo Canyon may be underdesigned to only withstand 89% of the stresses from a Hosgri earthquake, which could lead to mass failures if such an earthquake occured.
III. PROGRAM WEAKNESSES 11.
Off-site consultant (s) worked to uncontrolled documents on a generic basis, because Bechtel and PGt<E sent them documents without letters of transmittal to assure that the documents were current when sent and were regularly updated.
- 12. There was consi derabl e confusion by off-site consultants as to the Diablo Canyon Project Office (DCPO) standards for acceptable calculation packages, which raises 4
~
.I questions whether DCPO procedures P-6 and I-26 were transmitted to the consultant (s) in a timely manner.
- 13. There was heav,y emphasis on procuction pressure at off-site consultant (s) that could override quality concerns, to the extent that quotas were imposed on the number of packages that had to be processed daily.
14.
Personnel at of f-si te consultant (s) often assumed their responsibilities for extended periods prior to recieving any quality assurance indoctrination.
- 15. Quality assurance surveillance activities at off-site consultant (s) were inadequate, because they only occured on an erratic bacis and were skipped for extended periods of time.
- 16. Quality assurence auditing activities at off-site consultant (s) were inadequate, because they failed to check for the full extent of prior errors that could be represented by specific findings.
As mentioned earlier, I will provide further issues and details on the allegations above, if the NRC chooses to correspond with me on these concerns. If there is such a correspondence, I request that the NRC contact me through Mr.
Devine.
I have read the above 5-page affidavit, and it i s true accurate and complete to the best of my knowledge and belief.
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o GENEFML ACKNOWLEDGMENT d
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On this the day of M --U 19 kefore me, State of[ (
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County of gf.-df.,,Q -
the undersigned Notary Public, personally appeared I '
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v OF F6CIAL SEAL s i' fh^ '
i l , iI personally known to me
,e N")T Any ppet,C . CAUSO8W A , [L.,foved to me on the basis of satisf acto 7 evidence t F AWCiP AL C5FiCE lh ,
subscribed to the i ALAME0A COUNTY , to be the person (sphose namepri 1.4
' wy cese E Wes uv 27.196' within instrument, and acknowledged that _jL executed it.
-.........:.---;,- ^ ' , - - t WITNESS my hand and of ficial seal.
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